President Obama introduced several new tax increases and incentives in a 2011 budget proposal that includes over a trillion dollars in tax changes. Most of the tax proposals are unchanged from those in last year’s budget proposal, but several important provisions were added that involve international taxes, worker classification, job creation and energy incentives.

1. Tax Legislative Update
Breaking news from Capitol Hill
from Grant Thornton’s National Tax Office
2010-02
Feb. 3, 2010
Obama unveils new tax proposals in 2011 budget Contact information
President Obama introduced several new tax increases and incentives in a 2011 budget Mel Schwarz
proposal that includes over a trillion dollars in tax changes. Most of the tax proposals are Partner
National Tax Office
unchanged from those in last year’s budget proposal, but several important provisions T 202.521.1564
were added that involve international taxes, worker classification, job creation and energy E Mel.Schwarz@gt.com
incentives. Dustin Stamper
Manager
National Tax Office
Some of the biggest changes came in the $122 billion international reform package, where T 202.861.4144
$88 billion was trimmed from last year’s $210 billion package. Most significantly, a E Dustin.Stamper@gt.com
proposal to reform the “check-the-box” rules is not included in this year’s budget, which www.GrantThornton.com/tax
also softens a provision meant to limit the benefits of deferring foreign income. One new
international proposal would tax “excess returns” associated with transfers of intangibles
offshore.
The president added several “economic recovery” tax proposals to the handful of
proposed tax incentives. The budget proposes extending bonus depreciation rules through
2010, increasing Section 179 expensing limits and creating a new temporary job creation
tax credit. The president also still supports extending the 2001 and 2003 tax cuts for
individuals with income under $200,000 (single) and $250,000 (married).
But like last year, the bulk of the tax package consists of proposals that will increase taxes,
raising revenue by an estimated $1.4 trillion with:
• $122 billion from changes in international taxation;
• $39 billion for repealing tax incentives for fossil fuels like oil, gas and coal;
• $307 billion general revenue raisers such as LIFO repeal and carried interest; and
• $969 billion from a rollback of the Bush tax cuts for individuals earning more than
$200,000 (single) or 250,000 (married).
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2. Last year, the revenue from many of these offsets was dedicated for health care reform.
Healthcare reform now receives a separate $150 billion allowance in another part of the
budget, while most of the tax offsets are retained as general tax proposals. The president
also abandoned climate change legislation as a revenue source for permanently extending
the Making Work Pay Credit. This year’s budget would extend the credit for only one year
and instead calls for revenue neutral energy and climate change legislation.
The president for the first time proposed tightening the rules for classifying workers as
employees or independent contractors — an issue he championed while in the Senate.
The budget expands the proposed repeal of oil and gas incentives to cover many coal-
related incentives. It also includes the administration’s recent financial industry tax
proposal.
It’s important to remember that many of the tax proposals will remain controversial, and
there is no guarantee they will be enacted. A presidential budget proposal is important, but
it is far from the last word. Some of the tax proposals will be examined carefully by
Congress, while others may not be considered this year, or ever.
Business tax incentives
QSB stock ($8 billion) – The budget proposes to increase the exclusion for qualified
small business (QSB) stock to 100 percent and eliminate the alternative minimum tax
(AMT) adjustment. The stimulus bill enacted in February 2009 increased the 50 percent
exclusion of gain from QSB stock to 75 percent for stock issued between Feb. 17, 2009,
and the end of 2010.
Research credit ($82.6 billion) – The budget again proposes to make the existing
research credit permanent.
Extenders ($46.7 billion) – The budget proposes extending through 2011 a number of
tax provisions known as “extenders” that expired at the end of 2009, including:
− subpart F “active financing” and “look through” exceptions;
− new markets tax credits and incentives for empowerment and community renewal
zones; and
− special 15-year recovery periods for qualified leasehold improvements and restaurant
property (the 15-year recovery period for qualified retail improvements, which also
expired at the end of 2009, is not mentioned).
Bonus depreciation ($20 billion) – The budget supports an extension of bonus
depreciation rules for property placed in service in 2010. The election to accelerate unused
AMT and research credits in lieu of bonus depreciation would also be extended.
Section 179 expensing ($753 million) – The budget proposes extending through 2010
the $250,000 limit for small business expensing under Section 179 and the phaseout
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3. threshold of $800,000. The budget would make permanent (after 2010) the 2006 limit of
$125,000 and the phaseout threshold of $500,000, indexed to inflation.
Section 48C advanced energy credit ($3.7 billion) – The budget proposes allocating an
additional $5 billion for the 30 percent Section 48C advanced energy product credit. The
2009 stimulus bill that created the credit only allocated $2.3 billion.
Housing tax credit grant extension ($2.2 billion) – This proposal would allow states
to elect cash assistance in lieu of low-income housing tax credits for 2010.
Job creation credit ($33 billion) – The Treasury budget explanation does not describe
the job creation credit, but the budget itself includes a line item for job creation legislation
that encompasses the president’s recent job credit proposal. The administration proposes
a credit of $5,000 for each net new job created in 2010 and a credit equal to 6.2 percent of
aggregate wage increases in excess of inflation. The total benefit of both would be capped
at $500,000 per employer.
Employer-provided cell phones ($2.8 billion) – This new proposal would remove the
tax consequences and substantiation requirements for employer-provided cell phones.
Currently, employers are denied a deduction for Section 280F “listed property” such as
cell phones unless business purpose and use are documented, and employees must include
the value of any personal usage of their cell phone in income.
New markets tax credit ($3.4 billion) – The administration proposes extending the new
markets tax credit for 2010 and 2011 with an allocation amount of $5 billion each year.
Retirement plan enhancements ($10.4 billion) – The budget proposes doubling the
$500 three-year “startup costs” tax credit for small employers who adopt a new qualified
retirement, SEP or SIMPLE plan. The budget would also require businesses with over 10
employees to offer automatic opt-out individual retirement accounts (IRAs) to employees.
Employers could claim a two-year tax credit for $25 per enrolled employee in the new
automatic IRAs, up to a maximum credit of $250.
General business revenue raisers
LIFO repeal ($59.1 billion) – The budget proposes the repeal of the last-in, first-out
(LIFO) method of accounting. Last year’s budget would have allowed taxpayers to include
any LIFO reserve in income ratably over eight years, but this year’s version extends that
period to 10 years.
LCM repeal ($7.5 billion) – The administration retained a proposal from last year that
would prohibit the use of lower-of-cost-or-market (LCM) and subnormal goods methods.
Any Section 481(a) adjustment resulting from an accounting method change away from
these methods would be included in income ratably over a four-year period beginning
with the year of change.
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4. Carried interest ($24 billion) – The administration again included a broad proposal to
change the taxation of “carried interest” in a partnership. Income and gain attributable to
a “services partnership interest” would be taxed as ordinary income and subject to self-
employment tax. A services partnership interest would be any interest in a partnership
held by a person who provides services to a partnership that is not attributable to
“invested capital” — invested capital is money or property contributed to the partnership.
The proposal is largely unchanged from last year and is significantly broader than the
carried interest provision passed by the House in 2009 (H.R. 4213). The House version,
while still broad, does not apply to all services provided to a partnership or all types of
partnerships. It instead covers specific investment services, defined as: advising as to the
advisability of investing in, purchasing or selling specified assets; managing, acquiring or
disposing of any specified asset; arranging financing with respect to acquiring specified
assets; and any activity in support of any of the foregoing services. It also applies only to
certain categories of partnerships.
Economic substance doctrine ($4.2 billion) – The administration continues to support
codifying the economic substance doctrine so that a transaction would be respected for
tax purposes only if it changes the taxpayer’s economic position in a meaningful way and
the taxpayer has a substantial economic purpose for the transaction.
Under the proposal, a transaction would not be considered to have a substantial economic
purpose solely by reason of profit potential unless the present value of the reasonably
expected pre-tax profit is substantial in relation to the net federal tax benefits arising from
the transaction. A 30 percent penalty (20 percent if there is adequate disclosure) would be
imposed on any understatement of tax that is attributable to a transaction lacking
economic substance. The penalty could be abated, but only in the same proportion as the
abatement of the under-lying tax liability. Interest attributable to an underpayment
attributable to a transaction lacking economic substance would not be deductible.
Worker classification ($7.3 billion) – This new proposal would make several changes to
tighten the rules for classifying workers as employees or independent contractors. The
administration would direct the IRS to issue new guidance on worker classification that
included narrowly defined safe harbors and rebuttable presumptions. The IRS would be
able to reclassify misclassified workers whose reclassification is prohibited under current
law. Service recipients would be required to disclose to independent contractors the tax
and benefit implications of their classification, and independent contractors could request
withholding on their payments.
Black liquor ($24 billion) – The budget proposes changing the requirements for the
$1.01 per gallon cellulosic biofuels credit to exclude the “black liquor” byproduct of paper
processing.
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5. Extension of FUTA ($14.2 billion) – The budget proposes making the federal 0.2
percent unemployment surtax permanent.
Superfund taxes ($18.9 billion) – The budget would reinstate superfund taxes, including
superfund excise taxes and the superfund environment income tax of 0.12 percent of
corporate income subject to the AMT.
Financial industry revenue raisers
Financial institution tax ($90 billion) – The budget includes the president’s recent
proposal to impose $90 billion in taxes on the liabilities of financial institutions with over
$50 billion in assets. Financial institutions covered by the tax would include insured
depository institutions, bank holding companies, thrift holding companies, insurance
companies, companies that own insured depository institutions and securities broker-
dealers. The tax would be equal to 0.15 percent of liabilities, which would be defined as
assets minus Tier 1 capital, FDIC deposits and any insurance policy reserves.
Forward sales of corporate stock ($295 billion) – A corporation that sells its stock
forward (agrees to issue the stock in the future) would be required to recognize imputed
interest income on the deferred payment.
Dealers of equity options and commodities ($2.6 billion) – Dealers in commodities,
commodities derivatives, securities or equity options would be required to treat income
from their dealer transactions as ordinary income. The ability to treat 60 percent of gain as
long-term gain would be repealed.
“Boot-within-the gain” repeal ($788 million) – The proposal would repeal the “boot-
within-gain” limitation under Section 356 for reorganizations in which the shareholder’s
exchange has the effect of the distribution of a dividend, as determined under Section
356(a)(2). A version of this proposal was included in this last year’s budget, but would
have applied only in cases where the acquiring corporation was foreign.
Insurance revenue raisers
COLI ($7.8 billion) – The budget includes a proposal that would restrict the use of
company-owned life insurance (COLI) by repealing the exception from the pro rata
interest rules for employees, officers and directors that are not also 20 percent
shareholders.
Insurance institutions and products ($6.6 billion) – The budget includes proposals to
expand the reporting of transactions in large life insurance contracts, modify the dividends
received deduction for life insurance company separate accounts and permit partial
annuitization of nonqualified annuity contracts.
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6. Fossil fuel revenue raisers
Oil and gas ($36.5 billion) – The administration did not re-propose an excise tax on oil
and gas produced on the outer continental shelf, but otherwise included all of last year’s
raisers applicable to the oil and gas industry:
− Modify Section 199 (the domestic production activities deduction) to exclude
revenues from the sale or disposition of oil, natural gas or a primary product thereof
− Repeal enhanced oil recovery credit
− Repeal marginal well tax credit
− Repeal percentage depletion for oil and natural gas and require cost depletion to be
used
− Require intangible drilling costs to be capitalized and recovered as depreciable or
depletable property
− Require tertiary injectant costs to be capitalized and recovered as depletable property
− Repeal passive loss exception for working interests in oil and natural gas properties
− Increase geological and geophysical amortization period from two to seven years for
independent producers
Coal and minerals ($2.3 billion) – The administration this year expanded its proposals
to repeal incentives for fossil fuels to include coal and other hard minerals such as lignite
and oil shale. The budget proposes to do the following:
− Modify Section 199 (the domestic production activities deduction) to exclude
revenues from the sale or disposition of coal, lignite, oil shale, other hard mineral
fossil fuels and products thereof
− Require exploration and development costs for coal, lignite, oil shale and other hard
mineral fossil fuels to be capitalized as depreciable or depletable property
− Repeal percentage depletion for coal, lignite, oil shale and other hard mineral fossil
fuels and require cost depletion to be used
− Require coal and lignite royalties to be taxed as ordinary income instead of capital
gains
International revenue raisers
Limiting deferral ($25.6 billion) – This proposal was included in last year’s budget, but
is limited this year to interest expense. Companies would be required to defer any interest
deductions allocated to foreign-source income to the extent the foreign-source income
associated with the interest expense is not currently subject to U.S. tax. This provision
would effectively limit the deferral regime by forcing U.S. companies to repatriate income
to use interest deductions.
Reforming the foreign tax credit ($59.4 billion) – The administration re-proposed two
major changes to foreign tax credit rules. First, a U.S. taxpayer would determine its
deemed paid foreign tax credit on a consolidated basis based on the aggregate foreign
taxes and earnings and profits of all of the foreign subsidiaries with which the U.S.
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7. taxpayer could claim a deemed paid foreign tax credit (including lower tier subsidiaries
described in Section 902(b)). Second, a matching rule would be adopted to prevent the
separation of creditable foreign taxes from the associated foreign income.
Intangible transfers offshore ($15.5 billion) – Under this new proposal, if a U.S. person
transferred an intangible to a related controlled foreign corporation subject to “a low
foreign effective tax rate” and there is evidence of “excessive income shifting,” then the
excessive return would be treated as subpart F income in a separate foreign tax credit
limitation basket.
Intangible property guidance ($1.2 billion) – This proposal would clarify the definition
of intangible property for purposes of Sections 367(d) and 482 to include workforce in
place, goodwill and going concern value. The proposal would also clarify that in a transfer
of multiple intangibles, the IRS could value the intangible properties on an aggregate basis
if it achieves a more reliable result. Intangible property would have to be valued at its
highest and best use.
Reinsurance premiums ($519 million) – Under this new proposal, a U.S. insurance
company would be denied a deduction in certain instances for certain reinsurance
premiums paid to affiliated foreign reinsurance companies with respect to U.S. risks
insured by the insurance company or its U.S. affiliates.
Limit earnings stripping by expatiated entities ($3.6 billion) – The budget proposes
revising Section 163(j) to tighten the limitation on the deductibility of interest paid by an
expatriated entity to related persons.
Repeal 80/20 company exception ($1.1 billion) – The budget proposes to repeal an
exception to the withholding rules for dividends and interest paid to a foreign person that
currently applies to domestic corporations if at least 80 percent of their gross income
during a three-year testing period is foreign-source and attributable to the active conduct
of a foreign trade or business.
Dividend withholding tax avoidance ($1.2 billion) – Income earned by foreign
persons with respect to equity swaps that reference U.S. equities would be treated as U.S.-
source to the extent that the income is attributable to dividends paid by a domestic
corporation — with exceptions for certain swaps.
Dual capacity taxpayers ($8.5 billion) –The proposal would treat a foreign levy that
would otherwise qualify as an income tax, or in lieu of tax as a creditable tax, only if the
foreign country generally imposes an income tax, as well as make other changes.
Offshore reporting ($5.4 billion) – The administration re-proposed without significant
changes a long list of proposals to tighten offshore financial reporting rules and penalties,
including proposals to do the following:
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8. − Modify the QI regime, including requiring greater reporting by QIs regarding U.S.
accounts
− Provide several special rules relating to non-QIs
− Require reporting of certain transfers of money or property to foreign financial
accounts
− Require disclosure of FBAR accounts to be filed with tax returns
− Require third-party information reporting regarding certain transfers of assets to
foreign financial accounts and the establishment of foreign financial accounts
− Create certain negative presumptions relating to FBARs
− Create certain negative presumptions relating to withholding on fixed or
determinable annual or periodical (FDAP) income payments to certain foreign
entities
− Extend the statute of limitations for certain reportable cross-border transactions and
foreign entities
− Impose double accuracy-related penalties on certain understatements involving
undisclosed foreign accounts
− Change the foreign trust reporting penalty
IRS administrative revenue raisers
IRS administrative procedures ($2.5 billion) – The budget proposes raising $2.5 billion
in new revenue through administrative changes and expansions in the IRS’s reach,
including proposals to do the following:
− Allow the IRS to issue levies before a Collection Due Process hearing for federal
employment tax liabilities of federal contractors identified by the automated Federal
Payment Levy Program
− Expand the ability of the IRS to levy 100 percent of federal contractor payments to
include payments for the sale or lease of real estate and other types of property not
considered goods or services
− Allow offset of federal refunds to collect state income tax regardless of where the
delinquent taxpayer resides
− Deny any deduction for punitive damages for a claim or settlement and include in
income any damages paid by insurance to the insured person
− Set standards for holding employee leasing companies jointly and severally liable or
solely liable for federal employment taxes
− Allow the IRS to collect court-ordered restitution immediately in a criminal tax case
without issuing a statutory notice of deficiency
− Eliminate the requirements that an initial offer-in-compromise include a
nonrefundable portion of the taxpayer’s offer
− Expand IRS access to the National Directory of New Hires data for general tax
administration purposes, including data matching, verification of taxpayer claims
during return processing, preparation of substitute returns for non-compliant
taxpayers and identification of levy sources
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9. − Make certain cases of repeated willful failure to file a tax return a felony instead of a
misdemeanor
− Treat Indian tribal governments that impose alcohol, tobacco, excise or income or
wage taxes as states for purposes of information sharing
− Create an exception to the three-year statute of limitations for assessment of federal
tax liability resulting from adjustments to state or local tax liability
Information reporting revenue raisers
Form 1099 for corporate payments ($9.2 billion) – The exception from Form 1099
reporting rules for payments to corporations would be removed so that all aggregate
payments over $600 in a year to a corporation would require the filing of an information
return.
Rental expense reporting ($3.1 billion) – This new proposal would require taxpayers
with rental income to report payments of $600 or more made to a service provider to the
IRS and the service provider on an information return such as Form 1099.
Contractor withholding ($704 million) – Contractors would have to furnish valid TINs
to any business that they receive at least $600 of payments from in a year or face
withholding.
Government payment reporting ($388 million) – The IRS would be authorized to issue
regulations to require information reporting on payments by federal, state and local
governments to government contractors for property or services.
Life insurance separate account reporting ($58 million) – Life insurance companies
would be required to report policyholder information to the IRS for each contract with a
cash value partially or wholly invested in a private separate account for any portion of the
taxable year.
Penalty revenue raisers
Information return penalties ($9 million) – Information return penalties would
generally be doubled for each return and the maximum yearly penalty would increase by
three times or more in most cases.
Bad check penalty ($27 million) – The penalty for submitting bad checks or money
orders to the IRS would be expanded to cover all commercially acceptable instruments of
payment that are not duly paid.
Electronic filing requirements (no revenue effect) – All corporations and partnerships
that are required to file Schedule M-3 would be required to file electronically. Exceptions
would be made for entities for whom electronic filing would create an undue financial
burden. The budget would create a new $25,000 penalty for corporations ($5,000 for tax-
exempt organizations) that do not comply with electronic filing requirements.
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10. Individual tax provisions
Tax cuts for income under $200,000 and $250,000 – The budget assumes the extension
of the Bush tax cuts in 2001 and 2003 for all taxpayers under the income threshold. This
includes the following:
− $1,000 child credit
− Marriage penalty relief
− 15 percent rate on capital gains and dividends
− Brackets up to the 28 percent bracket, including the expanded 10 percent bracket
Tax cuts for income over $200,000 or $250,000 ($965.9 billion) – For singles with over
$200,000 and joint filers with over $250,000 in modified AGI, the budget proposes a
number of significant tax increases, including proposals to do the following:
− Reinstate the pre-Bush top two marginal rates of 36 percent and 39.6 percent
− Impose a 20 percent rate on capital gains and dividends
− Reinstate the personal exemption phaseout (PEP) and three percent limitation on
itemized deductions (Pease) of the pre-Bush tax cut era
− Further limit itemized deductions by capping the applicable tax rate at 28 percent
Stimulus bill tax provisions ($157.5 billion) – The budget proposes making permanent
or temporarily extending several of the tax provisions from last year’s stimulus bill:
− The higher EITC credits for low-income joint filers and taxpayers with three or
more children would be made permanent (advanceable EITC would be repealed).
− The expansion of the Hope credit for qualified tuition into the American
Opportunity Credit would be made permanent (credit amounts and phaseout
thresholds would also be indexed for inflation).
− The Making Work Pay Credit ($400 for singles or $800 for joint filers subject to
income limits) would be extended for one year to apply in 2011.
− The $250 Economic Recovery Payment for Social Security recipients and certain
government retirees not eligible for the Making Work Pay Credit would be extended
for one year to apply in 2010.
− The 65 percent 15-month COBRA subsidy for certain employees that are
involuntarily terminated before Feb. 28, 2010, would be extended to provide
assistance for up to 12 months for those who are involuntarily terminated during the
remainder of 2010.
Child care credit ($12.6 billion) – The budget proposes increasing the AGI limit at
which the credit begins to phase out from $15,000 to $85,000. The budget also
accommodates a permanent extension of the increase in refundability that was passed as
part of the 2009 stimulus bill.
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11. Expanded saver’s credit ($29.8 billion) – The proposal would create a refundable credit
that provides a 50 percent match on the first $1,000 of savings for families ($500 for
singles). The credit would phase out for joint filers with AGI between $65,000 and
$85,000 and for singles with AGI between $32,500 and $42,500.
Alternative minimum tax ($659 billion) – The budget proposes to patch perpetually
(but not repeal) the individual AMT by indexing the 2009 AMT parameters (including tax
brackets, exemption amounts and the phaseout triggers) for inflation.
Estate tax changes
Exemption and rate ($262 billion) – The budget assumes the retroactive and permanent
extension of the estate, gift and generation-skipping tax rules applicable in 2009, including
the tax rates (45 percent) and exemption amounts ($3.5 million for estates).
Valuation discounts ($18.7 billion) – The administration proposes creating an
additional category of “disregarded restrictions” under Section 2704 that would be ignored
in valuing an interest in a family partnership. In certain circumstances, this would curb the
discounts taxpayers can achieve for transfer tax purposes by putting assets in a family
limited partnership. Broad regulatory authority would be granted to the IRS to determine
which restrictions should be disregarded, as well as to create safe harbors to permit
taxpayers to avoid these restrictions.
Minimum GRAT term ($3 billion) – The administration has again proposed a new
minimum term requirement of 10 years for grantor retained annuity trusts (GRATs). This
would make a GRAT a riskier planning technique because the transfer tax benefits of
GRATs are typically achieved when the grantor outlives the GRAT term. In addition, this
year’s proposal would also require the remainder interest of a GRAT to have a value other
than zero.
Consistency in valuations ($2.1 billion) – This proposal would limit the basis of
inherited property to the value the property is assigned for estate tax purposes (subject to
subsequent adjustments). The executor of an estate would be required to report the
valuations used in filing the estate tax return.
A note regarding revenue estimates:
All estimates are for the 10-year budget period from 2011 through 2020. The revenue
estimates in this paper follow the administration’s approach of not scoring AMT indexing
for inflation or the extension of the 2001 and 2003 tax cuts for individuals, including the
expansion of the child care and earned income credits. If those items were scored against
current law, they would be estimated to result in a revenue decrease of $3.7 trillion,
making the total estimate for all tax proposals (other than the proposed new jobs credit) a
revenue loss of $2.6 trillion.
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